REPUBLIC OF THE PHILIPPINES

6TH JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 30
ILOILO CITY

BRUCE WAYNE, Civil Case No. 80112

Plaintiff FOR: COLLECTION FOR A
SUM OF MONEY WITH
DAMAGES
- versus -

HARLEY QUINN,
Defendant

X-------------------------------------X

ANSWER

Defendant, through the undersigned counsel unto this Honorable Court,

hereby respectfully avers:

1. Paragraphs one (1) and two (2) of the Complaint are admitted;

2. Paragraphs four (4), five (5), and six (6) are denied for lack of
knowledge or information sufficient to form a belief as to the veracity or
falsity thereof, the allegations therein being matters known only to and are
within the control only of the plaintiff

3. Paragraph three (3) of the complaint is denied insofar as it alleges that

the debt has become due and demandable on January 01, 2018, the truth being
alleged in the special and affirmative defenses part herein below;

SPECIAL AND AFFIRMATIVE DEFENSES

1. On June 01, 2017, the plaintiff and defendant met at “Queen’s Court”,
a drive-in hotel located in Bolilao, Iloilo City, to transact business. During
their negotiations, plaintiff agreed to let defendant borrow a sum of five
million pesos (PHP 5,000,000.00) in cash. However, plaintiff said to
defendant that conducting business with her was “fruitful and enjoyable”, and
both the plaintiff and defendant agreed to meet at “Queen’s Court” at future
dates for business-related matters.

2. On August 02, 2017, during one of these transactions, plaintiff

confessed his affections to defendant. The defendant told the plaintiff that
she could not “retaliate his love” with her outstanding debt to him. In
response, plaintiff waived defendant’s debt to him as evidenced by Annex-1,
“Letter to H.”

3. However, four months thereafter, on December 02, 2017, the defendant

met and fell in love with another man, Joe Kerr. On December 10, 2017,
defendant ended her relationship with plaintiff. In a fit of desperation,
plaintiff sent her waves of text messages, instant messages, e-mails, and made
several calls during the day. Because of this, defendant changed her
cellphone number, telephone number, e-mail, and even residence on
December 26, 2017. Defendant stopped receiving further messages from the
plaintiff since then.

COMPULSARY COUNTERCLAIM

1. By reason of the abuse of right committed by the plaintiff and by

reason of the instant precipitate and unfounded suit, the defendant was
constrained to hire the services of a lawyer to defend her rights and interests
for a professional fee of one hundred thousand pesos (₱100,000.00) and two
thousand pesos (₱2,000.00) per court appearance;

2. Similarly, the plaintiff’s unfounded suit has caused the defendant

mental anguish, wounded feelings, sleepless nights, serious anxieties, and
other similar sufferings for which the defendant claims moral damages of two
hundred thousand pesos (₱200,000.00).

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed

to this Honorable Court the dismissal of the complaint for lack of merit with
costs against the plaintiff; and that the defendant’s compulsory counterclaim
be granted, i.e., moral damages of two hundred thousand pesos (₱200,000.00),
attorney’s fees of one hundred thousand pesos (₱100,000.00), and two
thousand pesos (₱2,000.00) per court appearance and costs of suit.

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

Iloilo City, January 8, 2018.

ATTY. SEAN GILSIE JIMENEZ

NOTARY PUBLIC for Province of Iloilo
Commission Serial No. 1422303
Until December 3, 2018
The Law Offices of Sean Jimenez
Roll of Attorney 081486
IBP No. 311086/10/31/14/Iloilo City
PTR No. 3052217/ Province of Iloilo
MCLE No. V-18070604
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF ILOILO ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, HARLEY QUINN, of legal age, after having been duly sworn in

accordance with law, depose and state that:

1. I am the petitioner in the above-stated case;

2. I caused the preparation of the foregoing petition;

3. I have read the contents thereof and the facts stated therein are true and
correct to my personal knowledge and/or on the basis of documents and
records in my possession;

4. I have not commenced any other action or proceeding involving the

same issue in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or proceeding

is pending in the Supreme Court, the Court of Appeals, or any other
tribunal or agency; and

6. If I should thereafter learn that a similar action or proceeding has been

filed or is pending before the Supreme Court, the Court of Appeals, or
any other tribunal or agency, I undertake to report that fact within five
(5) days therefrom to this Honorable Court.

________________________
HARLEY QUINN
Affiant
TIN 47712-441; Iloilo City
 ACKNOWLEDGMENT

(Republic of the Philippines)

City of Iloilo) S.S.

SUBSCRIBED AND SWORN to before me, a Notary Public, for and

in the City of Iloilo, this 5th day of January 2018 personally appeared:

Name Identification Card Issued On/At

Harley Quinn TIN ID Iloilo City, 03/20/16

all known to me to be the same person who executed the foregoing instrument
and hereby acknowledged to me that the same is their free and voluntary act
and deed.

This instrument consisting of four (4) pages, including this page on

which this acknowledgment is written refers to a COLLECTION FOR A
SUM OF MONEY and has been signed by the party and sealed with my
notarial seal.

WITNESS MY HAND AND NOTARIAL SEAL.

Doc. No.____; ATTY. SEAN GILSIE JIMENEZ

Page No.____; NOTARY PUBLIC for Province of Iloilo
Book No.____; Commission Serial No. 1422303
Series of 20___. Until December 3, 2018
The Law Offices of Sean Jimenez
Roll of Attorney 081486
IBP No. 311086/10/31/14/Iloilo City
PTR No. 3052217/ Province of Iloilo
MCLE No. V-18070604